Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Order Granting Approval of Proposed Rule Change as Modified by Amendment No. 1 Relating to MSRB Rule G-34, CUSIP Numbers and New Issue Requirements, to Establish a Transparency System for Municipal Auction Rate Securities and Municipal Variable Rate Demand Obligations, 1741-1743 [E9-441]
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Federal Register / Vol. 74, No. 8 / Tuesday, January 13, 2009 / Notices
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room on official business days between
the hours of 10 a.m. and 3 p.m. Copies
of such filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–ISE–
2008–101 and should be submitted on
or before February 3, 2009.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.7
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–413 Filed 1–12–09; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–59212, File No. SR–MSRB–
2008–07]
Self-Regulatory Organizations;
Municipal Securities Rulemaking
Board; Order Granting Approval of
Proposed Rule Change as Modified by
Amendment No. 1 Relating to MSRB
Rule G–34, CUSIP Numbers and New
Issue Requirements, to Establish a
Transparency System for Municipal
Auction Rate Securities and Municipal
Variable Rate Demand Obligations
January 7, 2009.
On November 18, 2008, the Municipal
Securities Rulemaking Board (‘‘MSRB’’),
filed with the Securities and Exchange
Commission (‘‘Commission’’ or ‘‘SEC’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2 a
proposed rule change to MSRB Rule G–
34, CUSIP Numbers and New Issue
Requirements, to establish a
transparency system for municipal
auction rate securities and municipal
variable rate demand obligations. The
proposed rule change was published for
comment in the Federal Register on
7 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
VerDate Nov<24>2008
19:10 Jan 12, 2009
Jkt 217001
November 28, 2008.3 The Commission
received three comment letters about
the proposed rule change.4 On January
2, 2009, the MSRB filed Amendment
No. 1 to the proposed rule change.5 This
order approves the proposed rule
change as modified by Amendment No.
1.
The proposed rule change would
establish a transparency system for
municipal Auction Rate Securities
(‘‘ARS’’) and municipal Variable Rate
Demand Obligations (‘‘VRDO’’). The
proposed rule change would: (i)
Implement an electronic system that
would collect and disseminate ARS and
VRDO information (the ‘‘Short-term
Obligation Rate Transparency System
Proposal’’); (ii) provide free public
access to information disseminated from
the Short-term Obligation Rate
Transparency (‘‘SHORT’’) System
through the MSRB’s Electronic
Municipal Market Access (EMMA)
system (the ‘‘EMMA short-term
obligation rate transparency service’’);
and (iii) amend Rule G–34, on CUSIP
numbers and new issue requirements, to
require brokers, dealers and municipal
securities dealers (collectively
‘‘dealers’’) to report, or ensure the
reporting of, interest rate and
descriptive information to the SHORT
System about ARS and VRDO following
an ARS auction or VRDO interest rate
reset. A full description of the proposal
is contained in the Commission’s
Notice.
As previously noted, the Commission
received three comment letters relating
to the proposed rule change.6 The
commenters generally supported the
concept of the proposal, but raised
concerns about the timing of its
implementation and certain data points
required to be collected. WFBS
commented only with respect to the
proposed effective date of the proposal.
3 See Securities Exchange Act Release No. 58998
(Nov. 21, 2008), 73 FR 72540 (Nov. 28, 2008)
(‘‘Commission’s Notice’’).
4 See letter from Jeffrey A. Schuh, Vice President,
Chief Compliance Officer, Wells Fargo Brokerage
Services, LLC (‘‘WFBS’’), dated December 18, 2008;
letter from Leslie M. Norwood, Managing Director
and Associate General Counsel, Securities Industry
and Financial Markets Association (‘‘SIFMA’’),
dated December 19, 2008; and letter from Michael
Decker and Mike Nicholas, Co-Chief Executive
Officers, Regional Bond Dealers Association
(‘‘RBDA’’), dated December 29, 2008.
5 In Amendment No. 1, the MSRB responded to
the three comment letters and, in response to the
comment letters, postponed the effective date of the
proposed amendments to Rule G–34 that relate to
Variable Rate Demand Obligations from January 30,
2009 to April 1, 2009. The proposed January 30,
2009 effective date for the proposed amendments to
Rule G–34 that relate to Auction Rate Securities
remains unchanged. This is a technical amendment
and is not subject to notice and comment.
6 See supra note 4.
PO 00000
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Fmt 4703
Sfmt 4703
1741
WFBS requested that the
implementation date of the proposal be
extended to four months from the date
of publication of the final rule so that
changes needed to support the SHORT
proposal could be designed, thoroughly
tested and implemented prior to the
proposed implementation date.
SIFMA supported the concept of
collection and display of auction rate
reset and remarketing rate reset
information, and focused its comments
on the timing of implementation and
certain data points proposed to be
collected. SIFMA stated that its
members feel strongly that January 30,
2009 is an unrealistically short
timeframe for implementing the new
regulatory requirement. SIFMA noted
that this year has been a historic year for
technological and operational issues
due to the market dislocation, and that
this as well as other issues have resulted
in many urgent technology and
operation projects queued at broker
dealer firms. SIFMA requested that the
proposal be delayed until the later of
April 1, 2009 or 90 days after the final
rule is approved by the SEC.
SIFMA also recommended that
maximum and minimum VRDO rates
not be required by the SHORT system.
SIFMA stated that the terms of VRDO
securities, by and large, have been
negotiated on a bespoke basis for each
transaction, that maximum rate
formulas are not standardized, and that
the administrative burden of calculating
and reporting the maximum rate for
every reset period is in excess of the
theoretical benefits it provides. SIFMA
also found no evidence of minimum
rates in any VRDO transaction and
stated that this is a superfluous field
which should be eliminated.
SIFMA stated that the broker dealers
regulated by the MSRB do not have
control over all of the ARS data points
being requested in the proposal because
broker dealers merely receive the
auction information from the auction
agent. Therefore SIFMA believes that
there should be an acknowledgement in
Rule G–34(c)(i) that the broker dealer is
only responsible for forwarding the
information it has received from the
auction agent and not be responsible for
the accuracy of that data.
RBDA stated in its letter that they
support the implementation of the
proposal as early as is practical, but
believe the intended effective date of
January 30, 2009 will not give market
participants sufficient time to
implement and thoroughly test
automated systems that will facilitate
compliance with rules associated with
the new system. RBDA requested that
the effective date for full
E:\FR\FM\13JAN1.SGM
13JAN1
1742
Federal Register / Vol. 74, No. 8 / Tuesday, January 13, 2009 / Notices
implementation of the proposal be
moved to April 1, 2009.
In Amendment No. 1, the MSRB
responded to the three comment letters
and, in response to the comment letters,
postponed the effective date of the
proposed amendments to Rule G–34
that relate to Variable Rate Demand
Obligations from January 30, 2009 to
April 1, 2009. The proposed January 30,
2009 effective date for the proposed
amendments to Rule G–34 that relate to
Auction Rate Securities remains
unchanged.
The MSRB noted in response to the
comments from SIFMA with respect to
the data points to be collected that the
SHORT System has been designed to
accept reports of VRDO in which the
minimum rate is unspecified by
allowing a dealer to not include a value
for the minimum rate. SIFMA also
stated that some VRDO maximum rates
are not stated in official documents for
the VRDO or are set pursuant to a
formula for which some VRDO
maximum rates are not able to be
calculated on the day that an interest
rate reset occurs. The MSRB stated that
the purpose of the requirement in the
proposed amendments to Rule G–34 to
report the current maximum rate is to
improve the availability of important
characteristics of a VRDO that have been
set by drafters of official documents for
VRDO. Therefore, dealers would be
required to report under the proposed
amendments to Rule G–34 VRDO
maximum rates that are stated in official
documents either as absolute values or
that are able to be calculated pursuant
to formulas on the day of an interest rate
reset. For VRDO maximum rates that are
not able to be calculated on the day an
interest rate reset occurs, the SHORT
System has been designed to accept a
value of ‘‘not calculable.’’ In addition,
the SHORT System also has been
designed to accept reports of VRDO in
which the maximum rate is unspecified
by allowing a dealer to not include a
value for the maximum rate.
The MSRB acknowledged that many
of the items of information about ARS
that would be required to be reported to
the MSRB under the proposed
amendments to Rule G–34 are produced
by ARS auction agents and that dealers
may not always be able to verify the
accuracy of such information.
Accordingly, the MSRB stated that it has
designed the SHORT System to accept
submissions of information directly
from ARS auction agents and has
incorporated into the proposed
amendments to Rule G–34 that dealers
‘‘may rely on the accuracy of such
information if the [dealer] makes a good
faith and reasonable effort to cause the
VerDate Nov<24>2008
19:10 Jan 12, 2009
Jkt 217001
Auction Agent to correct any
inaccuracies known to the [dealer].’’ In
the event that an ARS auction agent
does not submit information directly to
the SHORT System but instead a dealer
reports to the SHORT System
information it receives from the ARS
auction agent, the reporting dealer
would have a similar responsibility for
correcting any inaccuracies known to
the dealer in the data provided to it by
an ARS auction agent. Therefore, so
long as the dealer reports the
information about the auction as
provided by the ARS auction agent and
fulfills its responsibility to correct
known inaccuracies, and the dealer does
not itself introduce any inaccuracies to
the data submitted, the dealer would be
entitled to the same reliance as in the
case of a direct submission to the
SHORT System by the ARS auction
agent. The Commission believes that the
MSRB has adequately addressed the
concerns raised by SIFMA about the
collection of data points for VRDO and
ARS.
The MSRB filed Amendment No. 1 in
response to concerns raised by all three
commenters about the effective date of
the proposal. The proposed January 30,
2009 effective date for the proposed
amendments to Rule G–34 that relate to
Auction Rate Securities remains
unchanged. While the MSRB
acknowledged that some dealers may
need additional time to perform and test
system changes to report data to the
MSRB using an automated system, the
MSRB believes that dealers will be able
to report information about ARS to the
MSRB manually using the SHORT
System Web User Interface if those
system changes are not able to be fully
implemented by January 30, 2009,
particularly since the number of ARS
issues is relatively small. In addition,
since ARS are primarily a retail product,
the MSRB believes it is important to
provide transparency of ARS as early as
practicable. Accordingly, the MSRB
does not believe that a change to the
proposed January 30, 2009 effective date
for ARS is warranted. The Commission
agrees that a change to the proposed
January 30, 2009 effective date for ARS
is not warranted because the
dislocations in the ARS market
necessitate the improvement of price
transparency for ARS as soon as
possible.
Amendment No. 1 postpones the
effective date of the proposed
amendments to Rule G–34 that relate to
Variable Rate Demand Obligations from
January 30, 2009 to April 1, 2009. While
the SHORT System allows data to be
reported manually using the SHORT
System Web User Interface, the MSRB
PO 00000
Frm 00081
Fmt 4703
Sfmt 4703
agrees with commenters that manual
submission of data for VRDO would be
impractical in many cases due to the
high number of VRDO securities and the
frequency with which VRDO interest
rates reset. Therefore, the MSRB
believes that a revised effective date of
April 1, 2009 would allow additional
time for dealers to implement
automated systems to submit data about
VRDO to the SHORT System and should
address commenters concerns. The
Commission believes that this extension
provides a reasonable accommodation
to dealers.
The Commission has carefully
considered the proposed rule change,
the comment letters received, and the
MSRB’s response to the comment letters
and finds that the proposed rule change
is consistent with the requirements of
the Act and the rules and regulations
thereunder applicable to the MSRB 7
and, in particular, the requirements of
Section 15B(b)(2)(C) of the Act 8 and the
rules and regulations thereunder.
Section 15B(b)(2)(C) of the Act requires,
among other things, that the MSRB’s
rules be designed to prevent fraudulent
and manipulative acts and practices, to
promote just and equitable principles of
trade, to foster cooperation and
coordination with persons engaged in
regulating, clearing, settling, processing
information with respect to, and
facilitating transactions in municipal
securities, to remove impediments to
and perfect the mechanism of a free and
open market in municipal securities,
and, in general, to protect investors and
the public interest.9 In particular, the
Commission finds that the proposed
rule change is consistent with the Act
because it would serve as an additional
mechanism by which the MSRB works
toward removing impediments to and
helping to perfect the mechanisms of a
free and open market in municipal
securities by providing a centralized
venue for free public access to
information about ARS and VRDO. The
proposed rule change would provide
greater access to information about ARS
and VRDO to all participants in the
municipal securities market on an equal
basis thereby removing potential
barriers to obtaining such information
and will allow the municipal securities
industry to produce more accurate trade
reporting and transparency. These
factors serve to promote the statutory
7 In approving this proposed rule change, the
Commission notes that it has considered the
proposed rule’s impact on efficiency, competition
and capital formation. 15 U.S.C. 78c(f).
8 15 U.S.C. 78o–4(b)(2)(C).
9 Id.
E:\FR\FM\13JAN1.SGM
13JAN1
Federal Register / Vol. 74, No. 8 / Tuesday, January 13, 2009 / Notices
mandate of the MSRB to protect
investors and the public interest.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,10 that the
proposed rule change (SR–MSRB–2008–
07), as modified by Amendment No. 1,
be, and it hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.11
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–441 Filed 1–12–09; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–59203; File No. SR–
NASDAQ–2008–084]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Order
Approving Proposed Rule Change to
Require Limited Partnerships to Obtain
Shareholder Approval for the Use of
Equity Compensation and Make Other
Clarifying Changes to the Listing
Requirements for Limited Partnerships
January 6, 2009.
I. Introduction
On November 18, 2008, The NASDAQ
Stock Market LLC (‘‘Nasdaq’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
require limited partnerships to obtain
shareholder approval for the use of
equity compensation and to make other
clarifying changes to the listing
requirements for limited partnerships.
The proposed rule change was
published for comment in the Federal
Register on December 2, 2008.3 The
Commission received no comments on
the proposal. This order approves the
proposed rule change.
II. Description of the Proposal
Nasdaq’s current listing requirements
provide that issuers must obtain
shareholder approval for a variety of
corporate actions, including the
issuance of equity compensation.4
However, these requirements do not
currently apply to Limited Partnerships
10 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 59014
(November 25, 2008), 73 FR 73358.
4 See Nasdaq Rule 4350(i)(1)(A).
11 17
VerDate Nov<24>2008
19:10 Jan 12, 2009
Jkt 217001
(‘‘LPs’’).5 Nasdaq is proposing to expand
the requirement to obtain shareholder
approval for equity compensation to
entities that are LPs. As such, the
proposed rule would provide that each
issuer that is a limited partnership must
obtain shareholder approval when a
stock option or purchase plan is to be
established or materially amended or
other equity compensation arrangement
is to be made or materially amended,
pursuant to which stock may be
acquired by officers, directors,
employees, or consultants, as would be
required under Nasdaq Rule
4350(i)(1)(A) and IM–43540–5.6
In addition, Nasdaq proposes to make
two other changes to the listing
requirements for LPs. Specifically, the
Exchange proposes to amend the rules
applicable to LPs to require that: (1) the
auditor of a listed LP must be registered
as a public accounting firm with the
Public Company Accounting Oversight
Board (‘‘PCAOB’’), as provided for in
the Sarbanes-Oxley Act of 2002; 7 and
(2) an LP must notify Nasdaq of any
material non-compliance with the
qualitative listing requirements for LPs
in Rule 4360. Nasdaq states that when
it adopted these requirements for other
companies in 2003 in response to
requirements imposed by the SarbanesOxley Act, Nasdaq inadvertently
excluded LPs from these requirements.
The Exchange notes, however, that these
requirements are already applicable to
LPs. Specifically, with respect to the
proposed auditor registration
requirement, it is unlawful for an
auditor to participate in the preparation
or issuance of an audit report with
respect to any listed company,
including an LP, unless it is registered
with the PCAOB.8 With respect to the
proposed notification requirement, each
listed company is required to sign a
listing agreement prior to listing on
Nasdaq in which the company has
agreed to promptly notify Nasdaq in
writing of any corporate action or other
event which will cause the company to
cease to be in compliance with Nasdaq
listing requirements.9 As such, Nasdaq
asserts that these changes are simply
clarifying changes designed to highlight
the requirements and facilitate
understanding and compliance of the
rules by LPs.
5 See
Nasdaq Rules 4350(i)(1)(A) and 4360.
proposed Nasdaq Rule 4360(k).
7 Section 102 of the Sarbanes Oxley Act, 15 U.S.C.
7212.
8 Id.
9 See https://www.nasdaq.com/about/
Listing_Agreement.pdf.
6 See
PO 00000
Frm 00082
Fmt 4703
Sfmt 4703
1743
III. Discussion and Commission
Findings
After careful review, the Commission
finds that the proposed rule change is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to a national
securities exchange and, in particular,
with Section 6(b)(5) of the Act,10 which
requires, among other things, that the
rules of a national securities exchange
be designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to remove impediments to, and
perfect the mechanism of, a free and
open market and a national market
system and, in general, to protect
investors and the public interest, and
are not designed to permit unfair
discrimination between issuers.11
The Commission notes the
importance of shareholder approval
rules, as such rules provide
shareholders with a voice in
transactions that are material to, and
may have an effect on, their respective
investments. With respect to equity
compensation plans, shareholder
approval rules also help to protect
investors against the potential dilutive
effect of such plans. The Commission
acknowledges that treating LPs
differently with respect to certain
limited types of shareholder approval
rules may be appropriate given the
structure and use of LPs and the
expectations of investors in such
entities.12 However, as the Commission
has indicated previously, it believes that
the rationale for treating an LP
differently from other types of issuers
with respect to shareholder input on
equity compensation is less
compelling.13 Accordingly, the
Commission believes that it is
consistent with the protection of
investors and the public interest to
require LPs to obtain shareholder
approval for the issuance of equity
compensation, as it will ensure that
investors in LP securities have a check
on the potential dilution that may result
from the issuance of equity-based
awards. Further, by requiring LPs to
obtain shareholder approval for stock
10 15
U.S.C. 78f(b)(5).
approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
12 For a detailed discussion of the reasons that
LPs differ from other issuers and may be
appropriately excluded from certain shareholder
approval rules, see Securities Exchange Act Release
No. 55796 (May 22, 2007), 72 FR 29566 (SR–NYSE–
2007–28) (approving NYSE’s proposal to exempt
LPs from certain of its shareholder approval rules,
excluding its equity compensation requirement).
13 See id., 72 FR at 29567.
11 In
E:\FR\FM\13JAN1.SGM
13JAN1
Agencies
[Federal Register Volume 74, Number 8 (Tuesday, January 13, 2009)]
[Notices]
[Pages 1741-1743]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-441]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-59212, File No. SR-MSRB-2008-07]
Self-Regulatory Organizations; Municipal Securities Rulemaking
Board; Order Granting Approval of Proposed Rule Change as Modified by
Amendment No. 1 Relating to MSRB Rule G-34, CUSIP Numbers and New Issue
Requirements, to Establish a Transparency System for Municipal Auction
Rate Securities and Municipal Variable Rate Demand Obligations
January 7, 2009.
On November 18, 2008, the Municipal Securities Rulemaking Board
(``MSRB''), filed with the Securities and Exchange Commission
(``Commission'' or ``SEC''), pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act''),\1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to MSRB Rule G-34, CUSIP Numbers
and New Issue Requirements, to establish a transparency system for
municipal auction rate securities and municipal variable rate demand
obligations. The proposed rule change was published for comment in the
Federal Register on November 28, 2008.\3\ The Commission received three
comment letters about the proposed rule change.\4\ On January 2, 2009,
the MSRB filed Amendment No. 1 to the proposed rule change.\5\ This
order approves the proposed rule change as modified by Amendment No. 1.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 58998 (Nov. 21,
2008), 73 FR 72540 (Nov. 28, 2008) (``Commission's Notice'').
\4\ See letter from Jeffrey A. Schuh, Vice President, Chief
Compliance Officer, Wells Fargo Brokerage Services, LLC (``WFBS''),
dated December 18, 2008; letter from Leslie M. Norwood, Managing
Director and Associate General Counsel, Securities Industry and
Financial Markets Association (``SIFMA''), dated December 19, 2008;
and letter from Michael Decker and Mike Nicholas, Co-Chief Executive
Officers, Regional Bond Dealers Association (``RBDA''), dated
December 29, 2008.
\5\ In Amendment No. 1, the MSRB responded to the three comment
letters and, in response to the comment letters, postponed the
effective date of the proposed amendments to Rule G-34 that relate
to Variable Rate Demand Obligations from January 30, 2009 to April
1, 2009. The proposed January 30, 2009 effective date for the
proposed amendments to Rule G-34 that relate to Auction Rate
Securities remains unchanged. This is a technical amendment and is
not subject to notice and comment.
---------------------------------------------------------------------------
The proposed rule change would establish a transparency system for
municipal Auction Rate Securities (``ARS'') and municipal Variable Rate
Demand Obligations (``VRDO''). The proposed rule change would: (i)
Implement an electronic system that would collect and disseminate ARS
and VRDO information (the ``Short-term Obligation Rate Transparency
System Proposal''); (ii) provide free public access to information
disseminated from the Short-term Obligation Rate Transparency
(``SHORT'') System through the MSRB's Electronic Municipal Market
Access (EMMA) system (the ``EMMA short-term obligation rate
transparency service''); and (iii) amend Rule G-34, on CUSIP numbers
and new issue requirements, to require brokers, dealers and municipal
securities dealers (collectively ``dealers'') to report, or ensure the
reporting of, interest rate and descriptive information to the SHORT
System about ARS and VRDO following an ARS auction or VRDO interest
rate reset. A full description of the proposal is contained in the
Commission's Notice.
As previously noted, the Commission received three comment letters
relating to the proposed rule change.\6\ The commenters generally
supported the concept of the proposal, but raised concerns about the
timing of its implementation and certain data points required to be
collected. WFBS commented only with respect to the proposed effective
date of the proposal. WFBS requested that the implementation date of
the proposal be extended to four months from the date of publication of
the final rule so that changes needed to support the SHORT proposal
could be designed, thoroughly tested and implemented prior to the
proposed implementation date.
---------------------------------------------------------------------------
\6\ See supra note 4.
---------------------------------------------------------------------------
SIFMA supported the concept of collection and display of auction
rate reset and remarketing rate reset information, and focused its
comments on the timing of implementation and certain data points
proposed to be collected. SIFMA stated that its members feel strongly
that January 30, 2009 is an unrealistically short timeframe for
implementing the new regulatory requirement. SIFMA noted that this year
has been a historic year for technological and operational issues due
to the market dislocation, and that this as well as other issues have
resulted in many urgent technology and operation projects queued at
broker dealer firms. SIFMA requested that the proposal be delayed until
the later of April 1, 2009 or 90 days after the final rule is approved
by the SEC.
SIFMA also recommended that maximum and minimum VRDO rates not be
required by the SHORT system. SIFMA stated that the terms of VRDO
securities, by and large, have been negotiated on a bespoke basis for
each transaction, that maximum rate formulas are not standardized, and
that the administrative burden of calculating and reporting the maximum
rate for every reset period is in excess of the theoretical benefits it
provides. SIFMA also found no evidence of minimum rates in any VRDO
transaction and stated that this is a superfluous field which should be
eliminated.
SIFMA stated that the broker dealers regulated by the MSRB do not
have control over all of the ARS data points being requested in the
proposal because broker dealers merely receive the auction information
from the auction agent. Therefore SIFMA believes that there should be
an acknowledgement in Rule G-34(c)(i) that the broker dealer is only
responsible for forwarding the information it has received from the
auction agent and not be responsible for the accuracy of that data.
RBDA stated in its letter that they support the implementation of
the proposal as early as is practical, but believe the intended
effective date of January 30, 2009 will not give market participants
sufficient time to implement and thoroughly test automated systems that
will facilitate compliance with rules associated with the new system.
RBDA requested that the effective date for full
[[Page 1742]]
implementation of the proposal be moved to April 1, 2009.
In Amendment No. 1, the MSRB responded to the three comment letters
and, in response to the comment letters, postponed the effective date
of the proposed amendments to Rule G-34 that relate to Variable Rate
Demand Obligations from January 30, 2009 to April 1, 2009. The proposed
January 30, 2009 effective date for the proposed amendments to Rule G-
34 that relate to Auction Rate Securities remains unchanged.
The MSRB noted in response to the comments from SIFMA with respect
to the data points to be collected that the SHORT System has been
designed to accept reports of VRDO in which the minimum rate is
unspecified by allowing a dealer to not include a value for the minimum
rate. SIFMA also stated that some VRDO maximum rates are not stated in
official documents for the VRDO or are set pursuant to a formula for
which some VRDO maximum rates are not able to be calculated on the day
that an interest rate reset occurs. The MSRB stated that the purpose of
the requirement in the proposed amendments to Rule G-34 to report the
current maximum rate is to improve the availability of important
characteristics of a VRDO that have been set by drafters of official
documents for VRDO. Therefore, dealers would be required to report
under the proposed amendments to Rule G-34 VRDO maximum rates that are
stated in official documents either as absolute values or that are able
to be calculated pursuant to formulas on the day of an interest rate
reset. For VRDO maximum rates that are not able to be calculated on the
day an interest rate reset occurs, the SHORT System has been designed
to accept a value of ``not calculable.'' In addition, the SHORT System
also has been designed to accept reports of VRDO in which the maximum
rate is unspecified by allowing a dealer to not include a value for the
maximum rate.
The MSRB acknowledged that many of the items of information about
ARS that would be required to be reported to the MSRB under the
proposed amendments to Rule G-34 are produced by ARS auction agents and
that dealers may not always be able to verify the accuracy of such
information. Accordingly, the MSRB stated that it has designed the
SHORT System to accept submissions of information directly from ARS
auction agents and has incorporated into the proposed amendments to
Rule G-34 that dealers ``may rely on the accuracy of such information
if the [dealer] makes a good faith and reasonable effort to cause the
Auction Agent to correct any inaccuracies known to the [dealer].'' In
the event that an ARS auction agent does not submit information
directly to the SHORT System but instead a dealer reports to the SHORT
System information it receives from the ARS auction agent, the
reporting dealer would have a similar responsibility for correcting any
inaccuracies known to the dealer in the data provided to it by an ARS
auction agent. Therefore, so long as the dealer reports the information
about the auction as provided by the ARS auction agent and fulfills its
responsibility to correct known inaccuracies, and the dealer does not
itself introduce any inaccuracies to the data submitted, the dealer
would be entitled to the same reliance as in the case of a direct
submission to the SHORT System by the ARS auction agent. The Commission
believes that the MSRB has adequately addressed the concerns raised by
SIFMA about the collection of data points for VRDO and ARS.
The MSRB filed Amendment No. 1 in response to concerns raised by
all three commenters about the effective date of the proposal. The
proposed January 30, 2009 effective date for the proposed amendments to
Rule G-34 that relate to Auction Rate Securities remains unchanged.
While the MSRB acknowledged that some dealers may need additional time
to perform and test system changes to report data to the MSRB using an
automated system, the MSRB believes that dealers will be able to report
information about ARS to the MSRB manually using the SHORT System Web
User Interface if those system changes are not able to be fully
implemented by January 30, 2009, particularly since the number of ARS
issues is relatively small. In addition, since ARS are primarily a
retail product, the MSRB believes it is important to provide
transparency of ARS as early as practicable. Accordingly, the MSRB does
not believe that a change to the proposed January 30, 2009 effective
date for ARS is warranted. The Commission agrees that a change to the
proposed January 30, 2009 effective date for ARS is not warranted
because the dislocations in the ARS market necessitate the improvement
of price transparency for ARS as soon as possible.
Amendment No. 1 postpones the effective date of the proposed
amendments to Rule G-34 that relate to Variable Rate Demand Obligations
from January 30, 2009 to April 1, 2009. While the SHORT System allows
data to be reported manually using the SHORT System Web User Interface,
the MSRB agrees with commenters that manual submission of data for VRDO
would be impractical in many cases due to the high number of VRDO
securities and the frequency with which VRDO interest rates reset.
Therefore, the MSRB believes that a revised effective date of April 1,
2009 would allow additional time for dealers to implement automated
systems to submit data about VRDO to the SHORT System and should
address commenters concerns. The Commission believes that this
extension provides a reasonable accommodation to dealers.
The Commission has carefully considered the proposed rule change,
the comment letters received, and the MSRB's response to the comment
letters and finds that the proposed rule change is consistent with the
requirements of the Act and the rules and regulations thereunder
applicable to the MSRB \7\ and, in particular, the requirements of
Section 15B(b)(2)(C) of the Act \8\ and the rules and regulations
thereunder. Section 15B(b)(2)(C) of the Act requires, among other
things, that the MSRB's rules be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, to foster cooperation and coordination with
persons engaged in regulating, clearing, settling, processing
information with respect to, and facilitating transactions in municipal
securities, to remove impediments to and perfect the mechanism of a
free and open market in municipal securities, and, in general, to
protect investors and the public interest.\9\ In particular, the
Commission finds that the proposed rule change is consistent with the
Act because it would serve as an additional mechanism by which the MSRB
works toward removing impediments to and helping to perfect the
mechanisms of a free and open market in municipal securities by
providing a centralized venue for free public access to information
about ARS and VRDO. The proposed rule change would provide greater
access to information about ARS and VRDO to all participants in the
municipal securities market on an equal basis thereby removing
potential barriers to obtaining such information and will allow the
municipal securities industry to produce more accurate trade reporting
and transparency. These factors serve to promote the statutory
[[Page 1743]]
mandate of the MSRB to protect investors and the public interest.
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\7\ In approving this proposed rule change, the Commission notes
that it has considered the proposed rule's impact on efficiency,
competition and capital formation. 15 U.S.C. 78c(f).
\8\ 15 U.S.C. 78o-4(b)(2)(C).
\9\ Id.
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\10\ that the proposed rule change (SR-MSRB-2008-07), as modified
by Amendment No. 1, be, and it hereby is, approved.
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\10\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\11\
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\11\ 17 CFR 200.30-3(a)(12).
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Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9-441 Filed 1-12-09; 8:45 am]
BILLING CODE 8011-01-P